Richard S. Lehman and Associates
Handling the toughest, most sophisticated tax cases. Tax planning strategy, defending clients before the Internal Revenue Service,
Richard S. Lehman & Associates' practice is limited to matters involving all areas of Federal Income, Estate, and Gift Taxation, and Estate Administration.

Areas of Practice

Taxation - Domestic
In the domestic area, the firm has represented clients in almost every type of commercial endeavor, resulting in the firm’s familiarity and use of every form of entity for tax planning purposes. Taxation - Internationally the field of international law, the firm has had extensive experience with all areas of the Internal Revenue Code that apply to both non-resident aliens and foreign corporations investing or conducting business in the United States, and U.S. citizens and domestic corporations investing abroad.

Estate & Gift Taxation;
Litigation, Strategy and Trusts Estate Administration
The firm has broad experience in all phases of estate and gift tax laws applying to U.S. citizens and resident and non-resident aliens. This has included tax planning for numerous multi-million dollar estates, and the resolution of numerous controversies among decedent’s beneficiaries.

Taxation - International
In the field of international law, the firm has had extensive experience with all areas of the Internal Revenue Code that apply to both non-resident aliens and foreign corporations investing or conducting business in the United States, and U.S. citizens and domestic corporations investing abroad.

Asset Protection Planning
In today’s litigation oriented society, all of us face the risk of loss of significant assets as a result of seemingly insignificant actions. Because of this, individuals and businesses of all sizes must be prepared to protect assets by every legal means available.
The firm regularly counsels many on the proper use of the asset protection planning tools available for the protection of one’s hard earned assets.

Lloyd’s of London
The firm advises U.S. investors and entities operating within Lloyd’s of London, the more-than-300-year-old British insurance marketplace.

Firm Proflie

Firm Profile
Today’s tax and financial planning landscape is a complex one, undergoing constant change. If businesses and individuals expect to preserve assets, make the proper moves, keep abreast of changing legislation, and make sure that they legally pay the least amount of taxes, they must rely on tax attorneys.

Contact
Richard S. Lehman
Richard S. Lehman is a graduate of Georgetown Law School and obtained his master’s degree in taxation from New York University. He has served as a law clerk to the Honorable William M. Fay, U.S. Tax Court, and as Senior Attorney, Interpretative Division, Chief Counsel’s Office, Internal Revenue Service, Washington, D.C. Mr. Lehman has been practicing in South Florida for over 28 years. During Mr. Lehman’s career his tax practice has caused him to be involved in an extremely wide array of commercial transactions involving an international and domestic client base.

Articles

OFFSHORE BANKING: Americans With Foreign Bank Deposits And Unreported Income - A Stay Out Of Jail Card From The I.R.S.
On March 23, the Internal Revenue Service came up with a six month “Amnesty Program” to allow U.S. taxpayers with unreported income to disclose their foreign bank accounts without fear of any criminal tax penalties. The price is to pay the income tax, the interest on the income tax and two specific penalties on unreported income and foreign bank accounts for the years 2003 through 2008. The Amnesty Program terminates on September 23, 2009. **Extended to October 15, 2009.

Richard S. Lehman Articles on United States Taxation
Read artcles on Domestic Taxation, International Taxation, Estate & Gift Taxation, Internet Taxation and Asset Protection
Richard S. Lehman and Associates and lehmantaxlaw.com, is dedicated to expanding the global knowledge of taxation of foreign investors in the United States. Our articles on U.S. Taxation of Foreign Investors and pre-immigration tax planning are intended to provide the foreign investor, both corporate and individual, with a basic introduction to the tax laws of the United States as they apply to that foreign investor.
More Articles from Lehmantaxlaw.com

United States Taxation of Foreign Investors - Translated Versions currently available: French, Spanish, German, Italian
 Richard S. Lehman Esq and lehmantaxlaw.com, is dedicated to expanding the global knowledge of taxation of foreign investors in the United States. Our articles on U.S. Taxation of Foreign Investors are intended to provide the foreign investor, both corporate and individual, with a basic introduction to the tax laws of the United States as they apply to that foreign investor.download pdf of article in English
Pre Immigration Tax Planning for the Foreign Investor
Safeguarding The Immigrant's Financial Interests Prior to Residency.
Very often immigrating residents are unfamiliar with the tax laws of the United States, that they will face upon obtaining their resident status. Often this lack of knowledge can be costly with immigrants paying unnecessary taxes and burdening themselves with liabilities. The following is a checklist of issues that may be helpful to avoid these tax problems.
click here to download preimmigrationtaxplanning.pdf

Tax Planning for the Foreign Real Estate Investor
Tax Benefits and Tax Traps
Very often Foreign Investors are unfamiliar with the federal and state tax laws that they will face when investing in United States real estate. Often this lack of knowledge can be costly with foreign investors paying unnecessary taxes.
 click here to download taxplanningforeigninvestors.pdf

United States a tax haven for foreign investors and immigrants to the United States
As times become more and more troubled, the United States sees more than its share of immigrants fleeing dangers and coming here to stay; and foreign investors who want their money and second homes here. One concern that is often high on their list is the payment of United States Federal taxes, both income taxes and estate taxes. From a tax perspective there are both special advantages and traps for both would be immigrants to the United States and the foreign investor. This article will look at both the traps and the advantages.
http://www.lehmantaxlaw.com/foreigninvestors_taxhaven.html

DOMESTIC PROFESSIONALS MUST RESPOND TO UNSETTLED TIMES IN SOUTH & CENTRAL AMERICA
Unsettled times in Argentina, Venezuela, Columbia and other regions are leading to an "immigration of the wealthy". While racing to establish some sort of United States presence these people will need to take a lot of care and receive good professional advice if they are to avoid financial problems and delays.
http://www.lehmantaxlaw.com/immigrantstounitedstates.html

 

UnitedStates Taxation of Foreign Investors: This web site is intended to provide the foreign investor with only a basic introduction to the tax laws of the United States as they apply to that foreign investor. The narrative outline available from this site is available in 8 languages: English, French, Spanish, German, Italian, Arabic, Chinese, and Russian - www.unitedstatestaxation.com

English version: The following narrative outline is intended to provide the foreign investor, both corporate and individual, with only a basic introduction to the tax laws of the United States as they apply to that foreign investor. Hopefully, it will let the foreign investor know that they are welcome in the United States. More importantly, it should help the foreign investor know that the U.S. tax laws are complex and must be dealt with in a highly professional manner; if one is to avoid the tax traps and take advantage of the many tax benefits offered by the United States. http://www.lehmantaxlaw.com/unitedstatestaxation.html

Spanish translation: El siguiente resumen pretende presentar al inversionista extranjero, ya sea persona jurídica o natural, una introducción básica a las leyes tributarias de los Estados Unidos de la manera en que éstas se aplican al inversionista extranjero. Se espera que el inversionista extranjero sepa que está bienvenido en los Estados Unidos. Aún más importante, le debería ayudar al inversionista a tener presente que las leyes tributarias de los Estados Unidos son complejas y deben ser tratadas de una manera muy cuidadosa para así evitar las trampas fiscales y aprovechar los numerosos beneficios tributarios ofrecidos por los Estados Unidos. http://www.lehmantaxlaw.com/spanish_ustaxation.html

French translation: Ce guide descriptif aidera à fournir à l’investisseur étranger, en tant que société ou personne physique, une introduction de base aux lois fiscales aux Etats-Unis, telles qu’elles s’appliquent à l’investisseur étranger. Espérons que l’investisseur étranger se rendra compte qu’il est le bienvenu aux Etats-Unis. Ce guide devrait surtout informer l’investisseur étranger que les lois fiscales aux Etats-Unis sont complexes et qu’elles doivent être traitées avec une approche hautement professionnelle si on veut échapper aux pièges en matière fiscale et profiter des nombreux avantages fiscaux offerts par les Etats-Unis. http://www.lehmantaxlaw.com/french_ustaxation.html

German translation: Der folgende erzählende Abriss soll dem ausländischen Investor, sowohl einer Einzelperson als auch einer Firma, lediglich mit einer grundlegenden Einführung in das Steuerrecht der Vereinigten Staaten versehen, soweit es auf ausländische Investoren Anwendung findet. Hoffentlich lässt es ausländischen Investor wissen, dass sie in den U.S.A willkommen sind. Wichtiger jedoch ist, dass sie dem ausländischen Investor hilft, zu wissen, dass das U.S.-Steuerrecht komplex ist und in einer hochprofessionellen Weise behandelt werden muss, wenn man Steuerfallen vermeiden will und Vorteile aus den vielen Steuervorteilen, die die U.S.A. bieten, ziehen will. http://www.lehmantaxlaw.com/german_ustaxation.html

Italian translation: Il presente documento intende fornire all’investitore non statunitense, sia persona fisica che giuridica, unicamente una presentazione generale del sistema fiscale degli Stati Uniti che li può riguardare. Speriamo di riuscire a far sapere agli investitori di tutto il mondo che sono benvenuti negli Stati Uniti. Ancor più importante, desideriamo far sapere che la legislazione statunitense in materia tributaria è complessa, e deve essere affrontata in maniera professionale, se si desidera evitare le insidie fiscali, e sfruttare i vantaggi che sono offerti anche in questo campo dagli Stati Uniti. http://www.lehmantaxlaw.com/italian_ustaxation.html

Arabic translation: http://www.lehmantaxlaw.com/arabic.pdf

Chinese translation: http://www.lehmantaxlaw.com/chinese.pdf

Russian translation: http://www.lehmantaxlaw.com/USTaxation_of_RussianInvestors.pdf

 

TV & Web

Ponzi SchemeTax Loss: www.PonziSchemeTaxLoss.com New Web Site Offers Tax Recovery Advice for Victims of Bernard Madoff and other Ponzi Schemes:

Start Presentation 50-minute web seminar: For victims of Ponzi Schemes and financial professionals.
Learn how recovery through the "Tax Refund" is quick and reliable.

Resources for the web seminar:
  1. Seminar Outline - download pdf
  2. Revenue Ruling (relates to The Law) - download pdf
  3. Revenue Procedure (relates to Safe Harbor) - download pdf
  4. Start presentation now

Bernard Madoff Tax Loss - REPORT NO. 1 view report or download as pdf
The following is Report No. 1 in what is intended to be a series of reports focusing on the tax benefits available as a result of the Bernard Madoff fraud. These Reports are not intended to be and can not serve as legal advice to any reader. Each taxpayer has their own unique factual situation which is going to need to be reviewed by tax advisors and litigation counsel before any legal conclusions can be reached. The Reports are being made in a series form since there is still a great deal of facts to be uncovered in the Bernard Madoff fraud. These facts are going to be extremely important in coming to conclusions about tax positions.

Bernard Madoff Tax Loss - REPORT NO. 2 view report or download as pdf
This phrase determines whether a deduction for the theft loss in a Ponzi scheme, such as Madoff's, should be taken in the year it is discovered or some other future year. The law does not permit the deduction to be claimed in a year prior to the year of discovery. SINCE THE TIMING OF THE THEFT LOSS DEDUCTION IS CRITICAL TO THE REAL ECONOMICS OF THE RECOVERY, THIS PHRASE IS ALL IMPORTANT.1 Therefore, before considering tax planning opportunities, this Report will study the phrase a reasonable prospect of recovery in more depth.

Is the Safe Harbor Worth it? - REPORT NO. 3 view report or download as pdf
Much has been written about the two documents released by the I.R.S. regarding the taxation of Ponzi schemes. There is Revenue Ruling 2009-9 (the "Rev. Rul.") in which the I.R.S. has clarified much of the unsettled law in this area. Likewise there is Revenue Procedure 2009-20 (the "Rev. Proc.") which provides an uncomplicated path through the law and will be helpful to thousands of Madoff victims who will have a short route to cash refunds from tax losses. This will be sorely needed by many. This is provided in what the I.R.S. calls a "safe harbor" procedure. The two documents by IRS are a good package and drafted in record time for any government agency. The I.R.S. worked well. HOWEVER, IT IS IMPORTANT TO REMEMBER IRS IS NOT IN BUSINESS TO GIVE BACK MONEY. The "safe harbor" needs to be carefully studied because it is a safe harbor that could be extremely expensive from a tax standpoint. It might be a safe harbor but the tax cost to dock your boat in this harbor could be very high.

View video from Richard Lehman and Steven Katzman re: Bernard Madoff Recovery: http://www.lehmantaxlaw.com/madoff_updates.html

Retainer Agreement: This is a retainer agreement and a look at some of the procedures that we will follow to make sure that you are aware of all of your options regarding maximizing all tax losses from Ponzi schemes. http://www.lehmantaxlaw.com/client_welcome.html

Update on the Wilson Lucom case in Panama - view now

Web site dedicated to the Lucom case:
English site: www.lucomchildren.com
Spanish site: http://www.lucomchildren.com/Lucom_spanish.html

Blog dedicated to the Lucom case: http://panamaexpatriates.blogspot.com/


Contact Richard S. Lehman
2600 N. Military Trail
Suite 270
Boca Raton, Florida 33431
Telephone: (561) 368-1113
Facsimile: (561) 998-9557
http://www.lehmantaxlaw.com/contact.html